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Such income includes foreign personal holding company income (FPHCI), generally consisting of dividends, interest, rents and royalties. However, if an S Corp doesn't meet ongoing activity requirements (at least 75% of gross receipts must be active), it can lose its S Corp status and become a personal holding company. Section 541 imposes an additional corporate-level tax on undistributed personal holding company income (UPHCI)--for example, passive income such as interest, dividends, royalties and sometimes rent income. |
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